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PRIVACY POLICY

Last updated December 2022

Kotter International, Inc., along with its subsidiaries and affiliates (collectively, “Kotter”), helps organizations mobilize their people to achieve unimaginable results at unprecedented speed. Kotter values your privacy and is committed to protecting your personal data. This online Privacy Policy applies to each of our websites that display or link to this Privacy Policy (including kotterinc.com, community.kotterinc.com, and learn.kotterinc.com), and html-formatted email messages we send to you that link to this Privacy Policy, all of which are collectively referred to in this Privacy Policy as the “Website”. This Privacy Policy applies to data collected by us through the Website and describes the information we collect and how we use it. We ask all users to review this Privacy Policy carefully. By visiting our Website, you are accepting the practices described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Website. We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice. We will post all changes to this Privacy Policy on this Website, and they will become effective upon posting. Your continued use of this Website will mean that you accept those changes.

Personal Information We collect

We collect and store personal information that you voluntarily provide to us or our third-party vendors through the Website, such as your name, email address, mailing address, phone number, voluntary posts, responses to survey and assessment questions, and login user credentials like usernames, passwords, and password hints. Registration may be required, and personal information collected in certain areas of the Website in which you specifically and knowingly provide such information, e.g., community postings, purchases, suggestions, or customer service requests.

Through your use of our Website, we may also gather certain information about such use (“Usage Information”). Generally, this information is collected through “traffic data.” We collect and store certain other information automatically whenever you interact with our Website. For example, we may collect your IP address, browser information, and reference site domain name every time you visit our Website. We also collect information regarding user traffic patterns and site usage.

Additionally, we use forms on our Website, each of which states what you will receive and can expect by providing your information. By submitting a form on our Website, you are consenting to an internal score and grade being tabulated and added to your Personal Information. This data will never be shared publicly and is only used to help us better identify what content and information you might find useful in the future.

Indirect Data Collection and Cookies/Pixel Tags

This Website automatically may collect certain device information such as your IP address, unique device identifier, Cookies (as discussed below), geographic data, country, browser, device operating system, application version, language settings, and pages that have been shown to you. Note, however, we do not consider this device information to be Personal Information except where we link it to you as an individual or where applicable law requires.

Cookies are small bits of information that are stored by your computer’s web browser.  Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

All browsers have a setting to opt you out of accepting cookies. Doing this will remove some of the functionality of ours, and other, websites. You can find steps to complete this using the links below:

The Cookies on our Website are generally divided into:

  • Strictly Necessary Cookies: Cookies that are necessary in order to operate our Website, such as to identify unique visitors and maintain the security of the Website.
  • Analytical Cookies: These cookies give us insights into how our Website is performing, how our Website is used, and how users interact with the Website. The information collected is anonymous and statistical.
  • Functional Cookies: Cookies that improve the functional performance of our Website and make it easier for you to use, including that you have previously visited our website in order to maintain your language preferences. These Cookies qualify as persistent Cookies, because they remain on your device so we can provide the same experience during your next visit to our website.
  • Targeting Cookies: Cookies placed by trusted partners which we use to understand how visitors interact with our Website and other third party websites you visit, including the pages you have visited and the links you have followed, in order to show you advertisements based on your interests (also known as interest based advertising). These Cookies qualify as persistent Cookies, because they remain on your device for us to use during a next visit to our Website.

Our Website employs cookies and/or pixel tags from the following third parties, as follows:

  • Google Analytics: this allows us to gather insights into how visitors use and interact with our Website. To obtain these insights, Google Analytics uses a number of cookies. The information collected is anonymous and statistical. To give you additional control, Google Analytics gives users the ability to opt-out of these cookies, http://tools.google.com/dlpage/gaoptout.
  • Google Ads: Google Ads is an online advertising program of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. We display Google ads and use Google remarketing and conversion tracking. The ads are displayed on Google’s advertising network web pages in response to search queries. We also use Google ads remarketing lists for search ads. This allows us to customize search ad campaigns for users who have visited our website before. This service allows us to combine our ads with specific search terms or to display ads to previous visitors promoting our services. We may therefore display interest-based ads on other websites within the Google advertising network (as “Google ads” in Google search or on other sites) to users of our website. You can find more information on data protection in the context of Google Ads at: https://policies.google.com/technologies/ads?hl=de
  • YouTube: YouTube cookies are used to track viewing statistics and assign a unique identifier to the device on which the video is viewed, enabling YouTube to recognize the device. This data is sent to Google for use in its advertising platforms.
  • Salesforce Pardot: we use Pardot to help us in our marketing efforts. These cookies provide insights into how visitors interact with our marketing materials. You can find more information about Pardot’s privacy policies here: https://www.salesforce.com/company/privacy/
  • Meta: we use cookies and pixel tags from Meta (Facebook and Instagram) to support our marketing, retargeting, and advertising efforts. You can find more information about Facebook’s privacy policies here: https://www.facebook.com/privacy/explanation
  • Twitter: we use cookies and pixel tags from Twitter to support our marketing, retargeting, and advertising efforts. You can find more information about Twitter’s privacy policies here: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
  • Zoominfo: we use this to collect statistics on users’ visits to our website, such as the number of visits, average time spent on the website and what pages have been read, preserve user states across page requests, and to distinguish between humans and bots.
  • LinkedIn: We also use conversion tracking on our Website with LinkedIn Insights Tag, a tool from LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2, Ireland. For more information on Conversion Tracking, see https://www.linkedin.com/help/linkedin/answer/67595/linkedin-conversion-trackingubersicht. Please be aware that LinkedIn’s data can be stored and processed so that a connection to the respective user profile is possible and LinkedIn can use the data for its own advertising purposes. For more information, please see LinkedIn’s privacy policy at https://www.linkedin.com/legal/privacy-policy. You can prevent LinkedIn from analyzing your usage behavior and from displaying interest-based recommendations at https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

How We use the Personal Information We Collect

We will never sell, trade, or give away your personal information. In addition to the uses stated elsewhere in this Privacy Policy, we use your personal information for various other purposes, including:

  • To provide you services, both through the Website and directly, to improve or enhance the Website, and to develop new products and services
  • To respond to your inquiries, to verify your information, and to share information with you, including sending you marketing materials, newsletters, information about our services, opportunities, and provide customer support
  • For our internal business purposes, such as audits, internal communications regarding clients, and determining the effectiveness of our promotional and marketing activities
  • For research, publication, development, benchmarking and norms, validation, longitudinal studies, and trend analysis
  • To ensure that our services conform with legal requirements like equal opportunity laws
  • To charge you for the purchase of services through one or more payment processing partners, and handle tax matters related thereto

We also use your name and other personal identifiers to associate and combine information about you that is collected from our Website with information about you collected through other services.

We disclose personal information to third parties as part of their providing services to us, including without limitation, website hosting and IT consulting services, marketing services, legal services, accountancy, and other administrative and back-up and security services.

We may also use your personal information to confer online course completion badges via a third-party credentialing entity, such as Credly.

We may access or disclose personal information about you, including the content of your communications, in order to: (a) comply with the law or respond to lawful requests or legal process; (b) protect the rights or property of our company or our customers, including the enforcement of our agreements or policies governing your use of our Website and services; or (c) act on a good faith belief that such access or disclosure is necessary to protect the personal safety of our employees, customers, or the public.

We may disclose personal information as part of a corporate transaction such as a merger or sale of assets. To that end, we may transfer your personal information as part of a merger, acquisition, or sale of all or a portion of our business.

Security of Personal Information

We maintain what we consider to be reasonable and appropriate technical and organizational measures designed to protect Personal Information from accidental loss, misuse and unauthorized or unlawful access or processing, disclosure, alteration and destruction. To the extent that we disclose Personal Information to third-party service providers, we require that such third parties also maintain reasonable security and confidentiality measures and use the Personal Information in accordance with our instructions and applicable law.

Cross-border Transfers

This Website may be operated, in whole or in part, from a country other than the United States. By using our Website, you consent to having your personal information transferred to and processed in a jurisdiction outside of the United States. We take appropriate steps to safeguard your personal information that is transferred. Where required by law, you can request a copy of such safeguards by contacting us as detailed below.

Retention

We retain your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained.

Choices and Access

You have the right to request to see your personal data in our database and request it be removed at any time. To make one of these requests, please send an email to info@kotterinc.com.

Applicable Law and Jurisdiction

Massachusetts, USA state law governs the interpretation of this Privacy Policy and applies to claims for breach regardless of conflict of laws principles. Both parties consent to exclusive jurisdiction and venue in courts sitting in Boston, MA, USA. Both parties waive all defenses of lack of personal jurisdiction and forum non conveniens.

Additional Information for California Residents

California Civil Code Section 1798.83 grants users of the Website who are California residents certain additional rights, as listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

  • Information. You can request the following information about how we have collected and used your personal information during the past 12 months:

o   The categories of personal information that we have collected.

o   The categories of sources from which we collected personal information.

o   The business or commercial purpose for collecting and/or selling personal information.

o   The categories of third parties with whom we share personal information.

o   Whether we have disclosed Your personal information for a business purpose, and if so, the categories of personal information received by each category of third party recipient.

o   Whether we’ve sold your personal information, and if so, the categories of personal information received by each category of third party recipient.

  • Access. You can request a copy of the personal information that we have collected about you during the past 12 months.
  • Deletion. You can ask us to delete the personal information that we have collected from you.
  • Opt-out of sales. If we sell your personal information, you can opt-out. In addition, if you direct us not to sell your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
  • Opt-in. If we learn that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent or guardian’s permission) to sell your personal information before we do so.
  • Non-discrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising Your rights.

To request to exercise your information, access and deletion rights, please send an email to info@kotterinc.com. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow Us to understand and respond to it.

Additional Information for European Territory Residents

In compliance with certain privacy laws, in particular the European General Data Protection Regulation (“GDPR”), we provide specific additional rights for individuals who interact with our Website such as the right to access, rectification, right to object, to complaint, erasure and blockage. More specifically and under certain circumstances:

  • the right to request information about whether and which personal information is processed by us, and the right to demand that personal information is rectified or amended.
  • the right to request that personal information should be deleted.
  • the right to demand that the processing of personal information should be restricted.
  • withdraw your consent to the processing and use of your personal information completely or partially at any time with future application.
  • have the right to obtain your personal information in a common, structured and mechanically readable format.
  • contact us if there are any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal information.
  • the right to complain to the responsible supervisory authority if believed that the processing of Your personal information is in violation of the GDPR.

Pursuant to the GDPR, citizens from “European Territories” mean the European Economic Area (EEA), the European Free Trade Area (EFTA) and Switzerland. For the purpose of this Privacy Policy, the term “European Territories” shall continue to include the United Kingdom.

Please email info@kotterinc.com with any questions about exercising any of the above rights.